ML18100B250
| ML18100B250 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 07/29/1994 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N94138, NUDOCS 9408110054 | |
| Download: ML18100B250 (6) | |
Text
Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Vice President and Chief Nuclear Officer July 29, 1994 NLR-N94138 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-272/94-16, 50-311/94-16, 50-354/94-15 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311, AND 50-354 Pursuant to the provisions of 10CFR2.201, this letter submits the response of Public Service Electric and Gas Company to the notice of violation issued to Salem and Hope Creek Generating Stations on June 30, 1994.
As required by the notice of violation and 10CFR2.201, this response includes a written statement or explanation for the violation and, where applicable, the corrective steps which have or will be taken to avoid further violations, and the date when full compliance will be achieved.
This information is provided in Attachment 1 to this letter.
Should you have any questions or comments on this transmittal, we will be pleased to discuss them with you.
Attachment
~408110054 940729 GDR ADOCK 05000272 PPR Sincerely,
Document Control Desk NLR-N94138 2 -
_ C Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. c. Stone, Licensing Project Manager U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall (S05)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 July 29, 1994
REF:
NLR-N94138 STATE OF NEW JERSEY
)
)SS.
COUNTY OF SALEM
)
- s. E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem and Hope Creek Generating Stations, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this 29th day of July, 1994.
~w~
ffe1*vVL Notary Publi; Ofew Jersey My Commission expires on April 21, 1998
A'rl'ACHMENT 1 Public Service Electric & Gas Company Docket Nos. 50-272; 50-311; 50-354 Salem Generating Station Units 1 & 2 Hope Creek Generating Station License Nos. DPR-70; DPR-75; NPF-57 Ref: NLR-N94138 In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix c, NRC has identified the below described violation:
Section 4.2.2.4, Vehicle Search, of the NRC-Approved Artificial Island Security Plan, Revision 4, dated November 30, 1993, states that "Vehicles are searched for weapons, explosives, incendiary devices and other contraband by an SFM [Security Force Member] at a guardhouse prior to entering the protected area.
The search consists of inspecting the cab, engine compartment, undercarriage, and cargo area."
Contrary t.o the above, on June 16, 1994, an SFM failed to search a vehicle properly until questioning by the NRC prompted supervisory direction to correct the search deficiency.
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company provides the following response:
I.
REASON FOR THE VIOLATION PSE&G does not contest the violation.
The violation occurred as a result of the failure of a particular Security Force Member (SFM) to search the battery compartment of a vehicle.
During a prior inspection, an incident occurred where a SFM did not search an external battery compartment without supervisory prompting.
As a result of that incident, corrective actions were taken that included the following:
+ A formal review was conducted with every SFM, during Enhancement Training, of all post orders, including PO lC -
Vehicle Search, which specifies that all compartments must be searched.
Each person signed an acknowledgement of reviewing the post order.
+ During the same Enhancement Training period, the Senior Security Regulatory Coordinator addressed all NRC inspection and QA audit concerns raised during the prior year and specified the level of attention to detail and performance expected.
Among the concerns was vehicle search, specifically the quality and methodology of undercarriage searches and the need to search battery boxes.
ATTACHMENT 1, (Cont'd) 2 -
As a result of this incident (6/16/94) a survey was conducted to assess the effectiveness of the corrective actions as indicated by the level of SFM awareness of vehicle search requirements and, specifically, the search of all compartments such as external battery boxes.
Seventy-nine SFMs, representing over sixty percent of the force, were surveyed.
Every person expressed a correct level of awareness, including recognition of the need 1 to search all compartments on the vehicle. It was concluded that the violation was not the result of inadequate corrective actions taken in response to the previous incident.
Further analysis determined the root cause of the violation to be the actual performance of the individual in question.
It was concluded that the SFM who failed to search the battery box had an extensive discipline history that is indicative of a poor attitude, which was expressed in this instance, by substandard performance.
In a post-incident interview with his supervisor and through a written report, the SFM made statements that reinforced the belief that his attitude was reflected in his performance.
Personnel records documenting this history are available for inspection by the NRC.
It has been concluded that the root cause of this incident was failure on the part of management, specifically the contractor management, to take appropriate action to correct poor performance of this SFM and to monitor overall disciplinary action that may be predictive of future performance.
II.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The SFM responsible for the violation was given a severe disciplinary penalty consistent with the security contractor's personnel policy.
The personnel records, including performance records, of the entire Security Force were reviewed.
No other persons were identified as having a discipline history which would be predictive of deficient performance.
In addition, increased supervisory oversight (self assessments of vehicle searches performed by PSE&G and contractor supervision) have demonstrated compliance with procedures - including searches of battery boxes.
No case has been observed in which a battery box was not searched.
This performance and the level of knowledge revealed by the survey, discussed above, indicate that the previous actions achieved the desired results.
ATTACHMENT 1, (Cont'd) 3 -
III. CORRECTIVE ACTIONS TO PREVENT RECURRENCE To assure that the potential for substandard performance as predicted by a security force member's disciplinary history does not reoccur, the PSE&G Nuclear Security Manager will be notified by the contractor management of all disciplinary actions taken relative to SFMs.
The notification will include a history of any prior occurrences.
The Nuclear Security Manager will assess the actions of the contractor to ensure that their personnel programs are consistent with the highest standards and are predictive of consistently meeting all of our regulatory requirements.
As an additional confirmation that the previous vehicle search training was effective, three Quality Assurance organizations (Salem Station QA, Hope Creek Station QA, and Nuclear QA) will conduct surveillance of vehicle searches over the next three calendar months, with particular attention to confirming that the searches are thorough and complete, and in every applicable case, include battery boxes.
IV.
STATUS OF COMPLIANCE Public Service Electric and Gas Company is in full compliance.
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